Composite GST assessment order for multiple years set aside; fresh year-wise proceedings permitted under the GST scheme.

A single composite GST assessment order covering multiple financial years was held unsustainable because separate tax periods must be dealt with year-wise under the GST scheme. Relying on a prior Division Bench view that one show-cause notice or assessment order cannot span more than one tax period where distinct periods are required, the High Court set aside the impugned order. The matter was remanded with liberty to initiate fresh proceedings separately for each assessment year, and the intervening period was directed to be excluded for limitation purposes.

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Issues: Whether a single composite assessment order covering more than one financial year is permissible under the GST framework and, if not, whether the impugned assessment order was liable to be set aside with liberty to initiate year-wise proceedings.

Analysis: The assessment order covered the period from 2018-19 to 2020-21 in a single proceeding. A prior Division Bench view was noted that a single show-cause notice or a single composite assessment order cannot be issued for more than one tax period where separate tax periods are required to be dealt with under the GST scheme. Since the petitioner pressed only this primary ground, the challenge was confined to the legality of the composite order, while the remaining grounds were left open.

Conclusion: The composite assessment order was held unsustainable and was set aside. The matter was remanded to the respondents with liberty to commence fresh proceedings separately for each assessment year, and the intervening period was directed to be excluded for limitation purposes.

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